CCC Net Zero Report: Aviation emissions to rise a little bit less fast than now … probably … speculative …

Date added: 2 May, 2019

The CCC has produced its report on how the UK should aim for zero-carbon GHG by 2050. There are a lot of mentions of aviation (most copied on this page, for ease of reference). The CCC advice is that aviation emissions must not rise as much as they are on track to do. International aviation emissions must be fully included in carbon targets, not just taken account of, as currently. They must be in the the 6th budget period (2033-37), on which the CCC will advise next year. So people will not be able to keep increasing the amount they fly by quite as much … But as it is a “hard to treat” sector, the CCC knows aviation will be emitting more CO2 than any other sector by 2050. The CCC’s “Further Ambition” scenario, setting out a pathway to net zero GHGs, anticipates that the aviation sector will still be emitting 31MtCO2 in 2050 (the current limit is 37.5MtCO2 per year). The CCC sees the use of synthetic fuels perhaps being 10% by 2050. It also hopes equivalent carbon, as produced by aviation, will be removed from the atmosphere through measures such as ‘direct air capture’ or BECCS, to be paid for by the aviation industry. But measures such as tree planting will not be enough. There will be a need to limit increases in air travel demand, but no ideas how to do that. The CCC will says it “will write to the Government later this year on its approach to aviation, building on the advice in this report.”

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CCC Net Zero Report: We’ll still be flying in 2050, but Government can no longer ignore aviation emissions in its climate policies

May 2 2019

(Aviation Environment Federation)

The UK should amend its legislation to commit to net zero greenhouse gas emissions by 2050, the CCC has advised, and this target should include the UK’s share of international aviation and shipping emissions, and be met through domestic action rather than international offset credits. This will require immediate steps from Government, industry and the public. Challenges that have not yet been confronted – such as aviation and shipping emissions – must now be addressed, the committee says.

To reinforce the importance of tackling emissions from all sectors, CCC has also recommended that international aviation emissions should be formally included in carbon budgets at the next available opportunity, beginning with the sixth budget period (2033-37), on which the CCC will advise next year. Currently under the Act, the 5-yearly carbon budgets are adjusted to take account of international aviation emissions but no formal requirement is put on the aviation sector to limit its emissions.

Aviation will be emitting more CO2 than any other sector by 2050, CCC anticipates

The CCC’s Further Ambition scenario, setting out a pathway to net zero GHGs, anticipates that the aviation sector will still be emitting 31MtCO2 in 2050. These emissions would need to be removed from the atmosphere through measures such as ‘direct air capture’ or BECCS, to be paid for by the aviation industry. While significant tree planting is required for emissions removal, the aviation sector should not rely on afforestation to remove its emissions, cautions CCC, given the limited scope that this offers for long term emissions removals at the required scale.

The Government currently predicts aviation emissions of over 40 Mt by 2050. Limiting them to 31 Mt will require a combination of demand constraint to limit passenger numbers to no more than a 60% increase on 2005 levels (for example through ‘policies to manage the use of airport capacity’), biofuels contributing 10% of the sector’s fuel needs, and more efficient aircraft that will improve the overall efficiency of the fleet by around 1.4% per annum for the next few decades, CCC advises. These figures are – in our view – very much at the speculative end of government and industry forecasts for the potential for technological improvements.

AEF’s Deputy Director Cait Hewitt, said

“The CCC’s recommendations set out a world-leading pathway for the UK to stop contributing to climate change in the future. It’s essential that Government recognises the need for commitments that cover all sectors, including aviation, and that don’t rely on international offsets.
“Reducing aviation emissions to 31MtCO2 by 2050, 25% less than the level currently predicted by the Department for Transport even after accounting for more sustainable fuels and likely technological improvements, will be extremely challenging. While technological improvements will be vital, we also need to think seriously about how to manage growth in the future, starting with saying no to unsustainable airport expansions.”

The Government’s plans for expansion at Heathrow, already the UK’s largest single source of carbon emissions, look increasingly difficult to justify. While yesterday’s court judgement rejected the climate challenges to the Government’s plans, the court made clear that an eventual decision on Heathrow’s third runway (expected around 2022) will need to be made in relation to the climate legislation and policy in force at the time. Given the growing public and political sense of a climate emergency, that legislation is very likely to put increasing pressure on the aviation sector.

https://www.aef.org.uk/2019/05/02/ccc-net-zero-report-well-still-be-flying-in-2050-but-government-can-no-longer-ignore-aviation-emissions-in-its-climate-policies/

Net Zero The UK’s contribution to stopping global warming

Committee on Climate Change

2nd May 2019

The full Committee on Climate Change report is at

https://www.theccc.org.uk/wp-content/uploads/2019/05/Net-Zero-The-UKs-contribution-to-stopping-global-warming.pdf

Other documents, data etc are at

https://www.theccc.org.uk/publication/net-zero-the-uks-contribution-to-stopping-global-warming/

Statement from the No 3^rd Runway Coalition

2 May 2019

Responding to the Net Zero report by the Committee on Climate Change, Paul McGuinness (Chair, No 3rd Runway Coalition), said:

“It’s notable that the Committee on Climate Change has gone out of its way to state that aviation must contribute to its new target of net-zero emissions by 2050 – no doubt mindful that aviation has doubled its emissions since 1990, despite a 40% fall across the whole economy”.

“This new target will almost certainly mean that Heathrow, already the largest single source of carbon emissions in the UK, will be unable to expand – unless government punitively offsets it with ham-fisted restrictions on regional economic activity and, in the process, surrenders any hope of creating a fairer, more balanced economy”.

Ends.

For more information, contact Rob Barnstone, 07806 947050 or rob@no3rdrunwaycoalition.co.uk

Some extracts from the report, dealing with aviation:

Challenges that have not yet been confronted must now be addressed by government. Industry must be largely decarbonised, heavy goods vehicles must also switch to low-carbon fuel sources, emissions from international aviationand shipping cannot be ignored, and a fifth of our agricultural land must shift to alternative uses that support emissions reduction: afforestation, biomass production and peatland restoration. Where there are remaining emissions these must be fully offset by removing CO₂ from the atmosphere and permanently sequestering it, for example by using sustainable bioenergy in combination with CCS.

• The UK should legislate as soon as possible to reach net-zero greenhouse gas emissions by 2050. The target can be legislated as a 100% reduction in greenhouse gases (GHGs) from 1990 and should cover all sectors of the economy, including international aviationand shipping.

• The aim should be to meet the target through UK domestic effort, without relying on international carbon units (or ‘credits’).

Setting and pursuing a UK net-zero GHG target for 2050 will confirm the UK as a leader among the developed countries on climate action. It demonstrates important principles of including emissions from all greenhouse gases and all sources (i.e. including international aviation and shipping), not relying on international offsetting and targeting ‘highest possible ambition’. Crucially it would be supported by the strong statutory emissions framework of the Climate Change Act.

Taken together, these measures would reduce UK emissions by 95-96% from 1990 to 2050. Tackling the remaining 4-5% would require some use of options that currently appear more speculative. That could involve greater shifts in diet and land use alongside more limited aviation demand growth, a large contribution from emerging technologies to remove CO₂ from the atmosphere (e.g. ‘direct air capture’), or successful development of a major supply of carbonneutral synthetic fuels (e.g. produced from algae or renewable power).

Aviation, agriculture and land must play their part. Updated evidence for aviationpoints to greater potential to reduce emissions, although we still expect the sector to emit more than any other in 2050. Our 80% scenarios did not assume any diet change, or major land use changes on the freed-up land, but these are both needed for a net-zero target.

The annual costs of removing emissions from the atmosphere are potentially large in our scenarios (e.g. of the order of £10 billion in 2050, possibly as high as £20 billion). These could be paid by industries, like aviation, that have not reduced their own emissions to zero. That would imply increasing costs (e.g. for flights) from 2035, as emission removals scale up in our scenarios.

In setting a net-zero target, these actions must be supplemented by stronger approaches to policy for industry, land use, HGVs, aviation and shipping, and GHG removals.

• Aviation and shipping. ICAO and IMO, the international agencies for aviation and shipping, have adopted targets to tackle emissions. The scenarios in this report go beyond those targets, suggesting increased ambition and stronger levers will be required in the long run. We will write to the Government later this year on its approach to aviation, building on the advice in this report.

GHG removals. The Government should expand support for early-stage research across the range of greenhouse gas (GHG) removal options, including trials and demonstration projects. It should also signal the longer-term market, which is clearly needed to meet a net-zero target, by developing the governance rules and market mechanisms to pay for emissions removals. Aviationstands out as an obvious sector that could require removals to offset its emissions – either through CORSIA (the international aviation industry’s planned trading scheme), the EU ETS or unilaterally the UK could support a net-zero target for aviation, requiring that all emissions are offset by removals.

[On the UK current target of 80% cut on the 1990 level by 2050]:

The Committee was clear that “any climate strategy should cover all GHGs and all sectors” and that the 80% target was designed on that basis. However, the Climate Change Bill did not include emissions from international aviation and shipping. The Committee therefore recommended that the target be legislated as “at least 80%” to cover the possibility that the sectors covered by the Bill may need to compensate for lower reductions in emissions from international aviation and shipping.

Sometimes ‘net-zero’ is used to refer to CO2 only, and sometimes it refers to all GHGs. There are some merits in each, which we consider in this report. Our recommendation in this report (Chapter 8) is that the UK should set a net-zero target to cover all GHGs and all sectors, including international aviation and shipping.

We make a detailed assessment in Chapters 5-7 of whether deeper reductions in UK emissions than currently targeted are feasible whilst still delivering on other government objectives and what these would cost. That assessment recognises areas where the UK’s challenge may be harder than that of other countries, for example due to our high population density and relatively high emissions from aviation.

Non-CO2 effects from aviation, which include the emission of nitrogen oxides and contrails, is an additional example of a human effect on the climate system that is also largely short-lived. Finding a way to eliminate these effects (which have an overall warming effect on the climate) before global temperatures peak would contribute to a lower peak warming if done without a compensating increase in CO2 emissions.

Alongside these big emitters the rest of the world is a large and growing part of global emissions. G20 countries make up around 78% of global emissions today but around half are currently not on track to achieve their NDCs. International aviation and shipping, which are excluded from national totals, represent around 2.5% of global GHG emissions and continued growing rapidly over recent years.

In 2017, UK GHG emissions105 per person were estimated to be 7.6 tCO2e/person, compared to a global average of 7.2 tCO2e/person (including emissions from land-use change and international aviationand shipping emissions).

[There is a short section on CORSIA on page 117]

Emissions from aviation can be limited through improvements to fuel efficiency, constraints on demand growth and switching to alternative fuels. However, deep emissions reductions in the aviation sector will be more difficult to achieve compared to other sectors (see Technical Report, Chapter 6). Current trends suggest a large share of emissions from aviation will have to be compensated through reductions elsewhere or through emissions removal from the atmosphere.

The UK has been an influential voice on international aviation and shipping issues within the ICAO and IMO (Section 1). For instance, the UK was a strong proponent of the recently approved criteria on ‘additionality’ and ‘no double counting’ for CORSIA carbon units, and it led a group of countries pushing the IMO to adopt more ambitious goals.

Some currently Speculative options would also be needed to get to a 100% reduction (i.e. to net-zero GHG emissions). Options include: further changes in demand (e.g. in aviation and diets) alongside more radical shifts in land use; extensive use of emerging technologies to remove CO2 from the atmosphere and safely store it (e.g. ‘direct air capture’); or successful development of a major supply of carbon-neutral synthetic fuels (e.g. produced from algae or renewable power).

Aviation. There are no commercially available low-carbon planes, so all flights currently rely on fossil fuels.

Aviation and shipping. Aviation emissions in the Core scenario are aligned with the Government’s objective to keep 2050 emissions at or below 2005 levels (i.e. 37.5 MtCO2). Shipping emissions are consistent with the internationally agreed target, which is to reduce global international shipping emissions by at least 50% below 2008 levels by 2050.

Aviation. Jointly with the Department for Transport, we commissioned a project assessing potential to reduce aviation emissions through new engine and aircraft designs, changes to airlines’ operations, and improvements to air traffic management.

(ii) Reducing emissions from hard-to-treat sectors – agriculture and aviation Agriculture and aviation stand out in our analysis as sectors where there are limited options currently available to reduce emissions. For agriculture that reflects some of the fundamental biological processes involved. For aviation it reflects the high energy-density required for aviation fuel.

Aviation. We have identified technical potential for additional emissions reduction beyond the Core scenario, including through more ambitious uptake of the Core options plus some use of hybrid-electric aircraft from the 2040s, and from reductions in design speeds of aircraft. However, the Further Ambition options for aviation would still result in emissions of 31 MtCO2e in 2050. This is because a fully zero-carbon plane is not anticipated to be available by 2050, particularly for long-haul flights which account for the majority of emissions. In total these harder-to-treat sectors would still have emissions of 55 MtCO2e in 2050 in this scenario, down from around 75 Mt in both 1990 and 2017.

. ‘BECCS (all sectors)’ covers the burning of biomass (including agricultural and forestry residues), waste wood, biomethane/biogas and the biogenic part of municipal and commercial and industrial waste (MSW/C&IW) in industry and for power generation, plus CO2 captured and stored from the production of biofuels for aviation and burning in homes (bioLPG in off-gas hybrid heat pumps).

[Table on Pag 155: Aviation

The grams CO2 per passenger kilometre is thought to be 110 in 2017, but 70 in the Core scenario for 2050, and 55 in the Further Ambition Scenario.
The amount of “sustainable biofuel” in use is thought to be 0% in 2017, 5% under the Core scenario in 2050, and 10% in the Further Ambition Scenario by 2050. ]

Further societal and behavioural changes. There is potential for larger changes in consumer choice, particularly in sectors where there are significant remaining emissions in 2050 (i.e. agriculture and aviation).

Aviation. The Further Ambition scenario allows a 60% increase in passenger demand above 2005 levels by 2050 (demand is currently around 30% higher). An additional reduction in emissions could be possible if demand were to be lower than this level (e.g. as an illustration, 20-40% above 2005 levels would imply a further saving in emissions of 4-8 MtCO2e). This could, for example, reflect a future change in consumer preferences and social norms, or more ambitious policy to limit growth in demand.

Synthetic fuels:

For example, to produce 115 TWh of synthetic jet fuel, which is the requirement after our Further Ambition options in aviation have been applied, would require around 200 TWh of zero-carbon electricity. This is equivalent to a further 33% of the total UK electricity generation requirements under Further Ambition.

Bioenergy: our approach is to preferentially use bioenergy in combination with CCS in order to maximise the level of negative emissions. However, both the ETC and EC [ Energy Transitions Commission (ETC) and the European Commission (EC] have substantial volumes of bioenergy used without CCS: for example over half used for aviation fuel (ETC). Our analysis suggests that this is not the most effective use given the relatively low level of emissions reduction it achieves compared to use with CCS.

Aviation. Only the departing flights are included in the UK’s territorial emissions, but clearly fewer departing flights will also be associated with fewer arriving flights. These will be counted in the territorial emissions of the countries from which they depart and will help to reduce global emissions but may not count in the UK’s consumption emissions.

Aviation. Emissions from aviation make up a much lower share of total emissions in all three devolved administrations compared to the UK. The vast majority (around 90%) of all UK air passengers travel through airports in England,157 with English airports acting as a hub for long-haul flights for passengers from all areas of the UK.

Constrained aviation demand. Plausible options for how aviation could become zerocarbon, even by mid-century, are lacking. Given a population that is anticipated to grow and rising incomes, some growth in demand is expected. However, this cannot be unfettered. We have maintained our previous assumption that demand grows by 60% relative to 2005 levels (25% relative to today) by 2050, but latest evidence on the opportunities to reduce the carbon-intensity of flying suggest that these should more than offset demand growth, leading to an overall fall in emissions of around 20%.

Aviation is the other big contributor to household emissions in our net-zero scenarios. Average household emissions range from 0.5-0.7 tCO2e (for context, a return flight from London to New York is currently around 1 tCO2e, half of which will be accounted for in the UK). Although technology is expected to help reduce emissions to some extent (e.g. aircraft fuel-efficiency improvements), achieving emissions reduction will require action from households:

‒ Choosing to fly less. Not everyone in the UK flies – Government surveys suggest that half of those surveyed had not flown at all in the preceding year. Those who do could replace short-haul flights with train journeys and choose to go on fewer long-haul flights.

‒ Offsetting emissions. In the long term, households that choose to continue to fly will still be able to, but their emissions will need to be offset by removing CO2 from the atmosphere (see section 4(h)). This could be done directly by the airline, with the cost of offsets added to the ticket price.

Ensuring that all policy decisions and sectoral strategies are informed by the requirement for them to contribute to the delivery of net-zero by 2050, e.g. through reforms to the ‘Green Book’. In a net-zero world there is no room for any sectors to remain ‘untouched’, including agriculture and aviation.

10% of the abatement is driven by consumer choices – shifting more quickly towards healthier diets, reducing growth in aviation demand and choosing products that last longer and therefore improve resource efficiency.

It will not be possible to get close to meeting a net-zero target without engaging with people or by pursuing an approach that focuses only on supply-side changes:

• At the moment, while the public are generally supportive of action to tackle climate change (Box 6.3), people who wish to reduce their impact on emissions are not provided sufficient support to make decisions that achieve this. People will need help to make low-carbon choices, both in terms of avoiding high-carbon activities and in adopting low-carbon technologies (see section 2(d)). This will require making low-carbon choices more available, provision of information, trials to see what works and policy that learns by doing (Box 6.4).

(g) Implications for aviation and shipping policy

A net-zero target will require more effort from all sectors, including aviation. The Committee’s advice is that a net-zero target for 2050 should cover all sources of GHG emissions, including international aviation and shipping. We will set out our recommended policy approach for aviation in follow-up advice to the Government later in 2019. Reducing emissions from aviation will require a combination of international and domestic polices, and these should be implemented in ways that avoid perverse outcomes (e.g. carbon leakage). A package of policy measures should be put in place that include carbon pricing, support for research, innovation and deployment, and measures to manage growth in demand:

• A long-term goal for international aviation emissions. The International Civil Aviation Organisation’s current carbon policy, CORSIA, has an end date of 2035. It will need to be based on robust rules that deliver genuine emission reductions (see section (h) below). A new long-term goal for global international aviation emissions consistent with the Paris Agreement would provide a strong and early signal to incentivise the investment in new, cleaner, technologies that will be required for the sector to play its role in meeting long-term targets. This is particularly important in aviation given the long lifetimes of assets. A similar approach has been agreed for global shipping emissions in the IMO, which has set a target for greenhouse gas emissions to be at least 50% below 2008 levels by 2050. 206 Net Zero – The UK’s contribution to stopping global warming | Committee on Climate Change

• Support for research, innovation, and deployment. Our analysis, and that of industry, suggests the largest contribution to reducing aviation emissions will come from new technologies and aircraft designs. Many of these developments are likely to be cost-effective, given their potential fuel savings. The Government should build on the approach set out in the Aerospace Sector Deal and Future Flight Challenge, and set out a clear strategy to ensure these technology solutions are developed and brought to market in a timely fashion. Synthetic fuels should not be a priority for government policy, but if industry wants to pursue them it should focus on demonstrating that these fuels, used in aviation, would be genuinely low-carbon, could become cost-competitive and are scalable in a global market.

• Measures to manage growth in demand. The Further Ambition scenario allows for a 60% growth in passenger demand by 2050 compared to 2005 levels (25% from now). Without additional policies being put in place, government projections suggest demand could be higher than this (e.g. their central case is for around a 90% growth in demand by 2050 on 2005 levels). New UK policies will therefore be needed to manage growth in demand. These could include carbon pricing, reforms to Air Passenger Duty, or policies to manage the use of airport capacity. Recent research commissioned by the DfT shows that UK policies to manage demand in aviation would not lead to carbon leakage from the UK to other countries in aggregate, given the relatively small amount of emissions affected. Policies to manage demand can therefore be pursued without significant risk of perverse impacts.

Action is also needed on non-CO₂ effects from aviation. These cause additional warming but should not be included within targets at this stage given their short-lived effects and uncertainty over how to measure and report their impact in the emissions inventory (Chapter 2). However, the Government should develop a strategy to ensure that these effects can be mitigated over the coming decades (e.g. by 2050-2070 for pathways that meet the Paris Agreement) without increasing CO₂ emissions. Demand-side measures are one way to reduce these effects.

The Government is aiming to publish an Aviation Strategy later in 2019, and published a consultation on this in December 2018. The consultation commits to regular updates of the Aviation Strategy. These regular reviews will provide an opportunity to respond to a future decision by Parliament to meet the UK’s commitments under the Paris Agreement. The final White Paper should aim to set more specific time-points for these reviews, and align them to developments in government climate strategy overall.

In principle, rather than offsetting remaining emissions with BECCS or DACCS, the aviation industry could instead use synthetic carbon-neutral fuels, thereby reducing the sector’s emissions to zero on a ‘gross’ basis rather than a ‘net’ basis. However, such synthetic fuels are likely to be expensive, entailing recycling captured CO₂ (e.g. via direct air capture) into a drop-in replacement for kerosene. As set out in Chapter 5, we expect these synthetic fuels to be significantly more expensive than achieving the same emissions outcome by sequestering the same amount of CO₂ geologically to offset remaining fossil kerosene use. However, given the equivalence of these options in terms of emissions, it is not necessary for the policy framework to prefer one or the other.

Aviation. Average abatement costs in aviation are negative in our scenarios, as cost saving fuel efficiency improvements (-£50/tCO₂e) more than offset higher costs from biofuels (£125/ tCO₂e). Aviation demand reduction is not assumed to result in resource costs, although there could be a welfare loss to individuals from flying less than they might otherwise wish to.

The Climate Change Act (section 30) allows for emissions from international aviation and shipping to be included from any future year. Since the current carbon budgets have been set without these emissions, we recommend their inclusion from the first year of the sixth carbon budget (i.e. 2033).

Emissions should be included based on the ‘bunker fuels’ methodology. [ Bunker fuels is the convention used for estimating and reporting international transport emissions to the UN. It is based on the amount of aviation and shipping fuel sold in the UK.]

Aviation and shipping. ICAO and IMO, the international agencies for aviation and shipping, have adopted targets to tackle emissions. The scenarios in this report go beyond those targets, suggesting increased ambition and stronger levers will be required in the long run. We will write to the Government later this year on its approach to aviation, building on the advice in this report.

GHG removals: Aviation stands out as an obvious sector that could require removals to offset its emissions – either through CORSIA (the international aviation industry’s planned trading scheme), the EU ETS or unilaterally the UK could support a net-zero target for aviation, requiring that all emissions are offset by removals.

See earlier:

Letter from Lord Deben, Chairman of the CCC – to Grayling on “Aviation 2050” the DfT’s aviation strategy green paper

February 13, 2019

In a letter to Chris Grayling, dated 12th February, Lord Deben provides the Committee on Climate Change’s views on the current aviation strategy green paper consultation, Aviation 2050 – The future of UK aviation [the aviation green paper]. He says “You will be aware that my Committee has been asked by Ministers to offer advice on the implications of the Paris Agreement for the UK’s statutory framework, including when ‘net-zero’ emissions can be achieved. A stronger UK target would require more effort from all sectors, including aviation. We intend to provide an updated view on the appropriate long-term ambition for aviation emissions within our advice on the UK’s long-term targets. We will publish our report in spring. Following that, we will write to you directly to set out the implications for the Aviation Strategy.” It also says: “The final white paper should further clarify that this will be met on the basis of actual emissions, rather than by relying on international offset credits.” And “Achieving aviation emissions at or below 2005 levels in 2050 will require contributions from all parts of the aviation sector,… It will also require steps to limit growth in demand. In the absence of a true zero-carbon plane, demand cannot continue to grow unfettered over the long-term.” Read the whole letter.

Click here to view full story…

and earlier:

Government tries to deny its climate responsibility to aim for 1.5C temperature rise, in pushing for 3rd Heathrow runway

January 14, 2019

The pre-trial hearing for the series of legal challenges against the Government’s decision to expand Heathrow takes place at the Royal Courts of Justice in London on Tuesday 15th January. In legal correspondence between the defendant (Government) and one of the claimants, Plan B Earth, the Government argues that “[Plan B] is wrong to assert that “Government policy is to limit warming to the more stringent standard of 1.5˚C and “well below” 2˚C’. This means that the Government is effectively denying that its own policy is to limit warming to the level that has been agreed internationally is required to avoid climate breakdown. The legal challenge brought by Plan B Earth and Friends of the Earth assert that the Government decision to proceed with Heathrow expansion was unlawful as it failed to appropriately consider climate change. Shadow Chancellor John McDonnell described the case as “the iconic battleground against climate change”. The Committee on Climate Change had previously expressed surprise that neither the commitments in the Climate Change Act 2008 nor the Paris Agreement (2015) were referenced in the Government’s Airports National Policy Statement (aka. the plans for a 3rd Heathrow runway).This is a huge inconsistency.